The product. A Wi-Fi-primary telephone service: connected to the public phone network, with an ordinary U.S. number, capable of being someone's primary line, purchasable without a full cellular bundle, and routing calls over Wi-Fi by default.
¶¶30–31, pp. 6–7The condition. Each carrier provides native Wi-Fi Calling only to consumers who maintain a qualifying cellular account with that carrier. The complaint alleges this is a commercial decision, not a technical requirement.
¶5, p. 2 ·
¶¶80–84, pp. 21–22The mechanism. Native Wi-Fi Calling needs two inputs controlled by different parties: carrier-controlled subscriber state, and platform-controlled handset functionality that recognizes it. An independent provider has no ordinary pathway to the first.
¶10, p. 3 ·
¶68, p. 18The agreement. The complaint alleges the carriers coordinated through the GSMA's Network 2020 program and its Green Button Promise to keep native voice and messaging under carrier control, and separately implemented that model through relationships with Apple, Google and Samsung.
¶13, p. 4 ·
¶¶113–128, pp. 33–39The pricing. The carriers market Wi-Fi Calling as “free” and at “no additional charge” while it is available only inside a cellular bundle. The complaint alleges this is below-cost pricing intended to exclude standalone competitors, recouped through the bundle.
¶89, p. 23 ·
¶¶229–232, p. 59The injury. VoIP-Pal alleges it was ready to enter this market and was foreclosed, losing sales, business value and profits.
¶¶187–194, pp. 50–51
